On December 19, 2025, Defense Pricing, Contracting, and Acquisition Policy (DPCAP) announced that DoW would release Department of War class deviations to the FAR and DFARS in two phases. Phase 1 — 31 class deviations to FAR and DFARS codified text — went effective at various points starting February 1, 2026. Phase 2 requires formal proposed FAR and DFARS rules issued for public notice and comment, planned for FY2026. Per DPCAP's official DFARS Revolutionary FAR Overhaul Class Deviations page, RedstoneGCI, and Wiley.
What changes in Phase 1
- 31 class deviations across FAR/DFARS
- DFARS text streamlined: removed, revised, or relocated procedures to DFARS PGI
- Cybersecurity provisions and clauses moved from FAR 52.204-xx to 52.240-xx
- Increased complexity around interpretation and definitions even as overall text shrinks
Why Phase 2 matters more
Class deviations are temporary — they let DoW test changes in real procurements without going through public comment. Phase 2 turns the most successful deviations into permanent rule changes. Public-comment windows are the moment industry can shape final language before it's locked in.
What to do
- Update FAR clause references in your contract templates — old 52.204-xx cyber clauses move to 52.240-xx
- Track DPCAP Phase 2 release calendar — file comments on the proposed rules that affect your business model
- Train BD/proposal teams to flag deviation clauses in agency-specific solicitations
